Subject: File No. S7-19-97
Date: 7/29/97 6:32 PM
From; SCM Portfolio Fund, Inc.
119 Maple Street
Post Office Box 947
Carrollton, GA 30117
Dear Mr. Katz:
We believe that the Form 24F-2 should continue to require information
about securities registered other than pursuant to rule 24f-2 and that
shares previously registered other than pursuant to rule 24f-2, sold, and
then redeemed should be "netted" as allowed under rule 24f-2. Those of us
who administer small funds which have registered a relative large number of
shares in years past may need several years to sell all of those shares and
those shares should be provided the same benefits as those shares
registered pursuant to rule 24f-2. And the Form 24F-2 should address the
previously registered shares in the calculation process.
Also, we oppose any requirement for an opinion of counsel during the
annual filing under rule 24f-2.
Thank you for consideration of the Commission of these concerns.
Sincerely,
Stephen C. McCutcheon
Chairman of the Board of Directors